Opinion
15253-20 22822-21
03-28-2023
ATKINSON, ANDELSON, LOYA, RUUD & ROMO A PROFESSIONAL LAW CORPORATION, ET AL Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES, JUDGE
These cases were on the Court's April 4, 2022 trial calendar for Los Angeles, California. The asserted deficiencies are large, mostly disputes about a law firm's substantiation of its expenses, and susceptible to settlement at IRS Appeals. We continued them to give IRS Appeals a chance to do so. Respondent recently reported that Appeals would be closing the cases as unagreed. We checked in with the parties today to discuss how to proceed. All agreed that substantiation cases this large should be capable of settlement of all or most issues. Petitioners promised that the next tranche of a thousand or so pages of documents will be sent to the IRS this week. The IRS understandably expects that it might have follow-up requests. The Court concludes that it need not set deadlines for the completion of informal discovery or for petitioner to produce any remaining relevant documents so long as this renewed spirit of cooperation prevails and the cases can stay at IRS Appeals. That means that the cases can stay on a status-report track for now, and it is
ORDERED that on or before April 28, 2022 the parties shall file a status report describing their progress toward settlement or a narrowing of the issues to be tried, and particularly their views on the progress of informal discovery.